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the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
In separate notices of deficiency, respondent determined
that petitioners are liable for the following deficiencies in
Federal income taxes:
Docket No. 2641-03S Geralyn M. Randich
Taxable Year Deficiency
2000 $6,091
Docket No. 21861-03S Steven M. Randich
Taxable Year Deficiency
2000 $6,683
The issues for decision are: (1) Whether $28,800 received
by petitioner Geralyn M. Randich pursuant to a judgment for
dissolution of marriage is includable in her income under section
71 as alimony income; and (2) whether petitioner Steven M.
Randich may deduct as alimony, pursuant to section 215, $28,800
that he paid to petitioner Geralyn M. Randich pursuant to the
judgment for dissolution of marriage.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the
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